03/08/2010
Would an ATM cash withdrawal be included for the cash reported on a CTR for multiple transactions over $10,000.00?
08/31/2009
We had an ATM robbed and lost more than 25K. I don't think we file a SAR on this, is this correct?
08/03/2009
We have a business account for an LLC that offers "financial and legal consulting". It was explained that they are heavily into loan modifications at this time. There are three members (one is an attorney) who have signing authority over the account. We noticed a high volume of debit card activity and most of it appears to be for personal as opposed to business purposes. For example, there are many POS purchases at high end stores such as Coach, Burberry, Saks 5 Avenue, plus many restaurants, spas, ice cream shops, etc. We asked the branch if they knew the purpose of this activity and they answered that they are for gifts for business referrals. To me this is nonsense. There are also many ATM withdrawals for the maximum daily limit ($600) that also do not appear to be for normal business purposes.I recall posting questions on BOL in the past about similar activity, such as college tuition payments from business accounts and the general consensus was that this should not be the bank's concern and should not result in a SAR filing (for tax evasion or avoidance). What is the consensus about the activity described above?
05/01/2009
By FinCEN Office of Regulatory Analysis
04/01/2009
Research of depository institution SAR (Form TD F 90-22.47) narratives that included the designated search terms retrieved 8,166 reports filed by 1,045 filers.
10/01/2008
Federal law enforcement agencies conducting a tax refund fraud investigation uncovered at least $13.1 million in fraudulently obtained federal and state tax refunds.
08/08/2008
In a case that started when a bank notified federal agents that it intended to file a SAR on two subjects, investigators utilized BSA records to uncover additional participants in a fraud scheme.
07/21/2008
If a customer makes a $10,000 cash withdrawal in our branch and makes a $300 ATM withdrawal at a bank-owned ATM, is a CTR for $10,300 required? If the ATM withdrawal were made at an ATM owned by another institution, would the CTR be required?
06/23/2008
We recently had a customer make two deposits through the ATM where there was no money in the ATM envelope. It was not discovered before the entire amount $1700 was withdrawn from the two accounts linked to the card. This is clear ATM fraud, but I didn't think a SAR should be filed since the criminal activity was less than $5000. Is that correct?
06/16/2008
I made about ten $500 ATM cash withdrawals in a month. I also made two $1,000 cash deposit during that span. Will my transaction be reported as suspicious activity? I am also a bank employee, will this matter? I know you have to report if you make $10,000 a day, but will my transactions during this month considered as structuring?